February 2, 2021
Via E-mail
Eleazer Klein, Esq.
Schulte Roth & Zabel LLP
919 Third Avenue
New York, NY 10022
Re: Exxon Mobil Corporation
Soliciting Materials filed February 1, 2021 pursuant to Rule
14a-12
Filed by Engine No. 1 LLC at al.
File No. 001-02256
Dear Mr. Klein:
We have reviewed the above-captioned filing and have the following
comment.
DFAN14A Filed February 1, 2021
General
1. We note the inclusion of materials published by third parties in your
soliciting materials in
reliance on Rule 14a-12(c)(2), including direct quotes indicating the
authors view that
Engine No. 1 s campaign can or will succeed. Please refrain from using
language forecasting
the results of the solicitation. Alternatively, provide us with your
analysis as to how Engine
No. 1 s use of such statements in its soliciting materials is consistent
with Rule 14a-9. Refer
to Note d to Rule 14a-9.
* * *
Please direct any questions to me at (202) 551-7951.
Sincerely,
/s/ Joshua Shainess
Joshua Shainess
Special Counsel
Office of Mergers
and Acquisitions